A blog about Cyber Security & Compliance

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data protection

Small and medium sized businesses are being warned to take note as a company which suffered a cyber attack is fined £60,000 by the UK Information Commissioner’s Office.

An investigation by the ICO found Berkshire-based Boomerang Video Ltd failed to take basic steps to stop its website being attacked.

Sally Anne Poole, ICO enforcement manager, said:

“Regardless of your size, if you are a business that handles personal information then data protection laws apply to you.

“If a company is subject to a cyber attack and we find they haven’t taken steps to protect people’s personal information in line with the law, they could face a fine from the ICO. And under the new General Data Protection Legislation (GDPR) coming into force next year, those fines could be a lot higher.”

She added:

“Boomerang Video failed to take basic steps to protect its customers’ information from cyber attackers. Had it done so, it could have prevented this attack and protected the personal details of more than 26,000 of its customers.”

The video game rental firm’s website was subject to a cyber attack in 2014 in which 26,331 customer details could be accessed. The attacker used a common technique known as SQL injection to access the data.

The ICO’s investigation found:

Boomerang Video failed to carry out regular penetration testing on its website that should have detected errors

The firm failed to ensure the password for the account on the WordPress section of its website was sufficiently complex

Boomerang Video had some information stored unencrypted and that which was encrypted could be accessed because it failed to keep the decryption key secure

Encrypted cardholder details and CVV numbers were held on the web server for longer than necessary

Ms Poole said:

“For no good reason Boomerang Video appears to have overlooked the need to ensure it had robust measures in place to prevent this from happening.

“I hope businesses learn from today’s fine and check that they are doing all they can to look after the customer information in their care.”

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In the last few months it appears that the North West of England has become a hub of nuisance calls after three raids undertaken on behalf of the Information Commissioners Office.

The ICO executed two search warrants this week, one in Gatley, Greater Manchester, on Wednesday and the other in Wilmslow, Cheshire, on Thursday.

Computers and phones were seized during the searches as the ICO continues to investigate nuisance calls prompted by the theft of people’s details from car repair centres throughout the UK. The items will now be subject to forensic examination and investigation.

Mike Shaw, ICO Criminal Investigations Group Manager, said:

“This illegal trade has multiple negative effects – both on the car repair businesses targeted for their customer data and the subsequent nuisance calls made to customers. These can be extremely unsettling and distressing.

“Our searches this week are the latest step in us tracking down the unscrupulous individuals involved in this industry. These people won’t get away with it – any person or business involved in the theft and illegal trade of personal data may find themselves subject to ICO action.”

ICO investigators are looking at how the data was stolen, who stole it and which companies have subsequently made calls to the public encouraging them to make compensation claims about to accidents they may have been involved in.

The ongoing investigation, named Operation Pelham, started in May 2016 and has so far involved:

December 2016. A business and two homes in Macclesfield and Heald Green were searched by ICO officers. The business was linked to the making of telephone calls to numbers originating from some of the car repair centres. Computers, telephones and documents were among items seized from the residential properties.

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Rob Luke’skeynotespeech ‘Will GDPR Change the World?’.

Introduction

Thank you.

Let me take a moment to thank TechUK for putting together this event and for offering me the platform to speak with you this morning.

Our Commissioner, Elizabeth Denham, has been clear that the ICO’s vision – of increasing data trust and confidence among the UK public – can only be achieved by working in partnership with the private, public and third sectors.

An important part of that is developing key relationships with representative or umbrella organisations as multipliers and amplifiers for our engagement with different constituencies. Helping us reach new or hard-to-reach audiences.

Our strong relationship with Tech UK is a great example of that partnership approach.

We appreciate the role you play in bringing together representatives from across the sector and your ongoing constructive dialogue with us around issues of importance to your members and the sector as a whole.

I’m glad to have the opportunity to continue that dialogue this morning.

Will GDPR change the world?

Will the General Data Protection Regulation change the world?

Wow, what a question. On the face of it, even the most ardent data protection advocate would struggle to make a case that a blandly titled piece of European legislation deserves that billing.

So despite my professional obligation to emphasise the importance of data protection in the digital age, I am not going to make the argument for the world revolving around GDPR.

What I will try to do is highlight some of the opportunities and challenges GDPR brings for organisations.

Ultimately, of course, GDPR is an indicator of change as much as it is an instigator. And no sector is more relevant to that rapidly changing landscape than yours.

GDPR is part of the response to the challenge of upholding information rights in the digital age. Of protecting the rights and interests of the individual in the context of an explosion in the quantity and use of data and in an environment of extremely rapid technological change.

So I feel it is particularly relevant to mark One Year To Go in dialogue with the tech sector in particular.

I should be clear early on that this is not a speech about Brexit or an exploration of the UK’s possible post-Brexit data protection framework.

In a pre-election period, and with the need to adhere to the guidance on purdah, I hope you will understand that I am not in a position to speculate about the post-Brexit environment, nor indeed to comment on proposals in political party manifestos.

I apologise in advance if there are questions, or elements of the panel discussion, where I am limited by the caution that purdah requires.

What we can safely say however, is that one way or another, GDPR is going to be an important part of the global data protection landscape over the years ahead, with great relevance to UK organisations, the public and their data.

Fit for the digital age

The moment at which GDPR takes effect in the UK on 25 May 2018 will of course mark a change. In delivering legislation fit for the digital age GDPR confers new rights and responsibilities and organisations need to be working now to prepare for them.

I assume that this audience has a familiarity with the core features of GDPR and the key requirements it places on organisations. I hope you have already deployed our ’12 steps to take now’ guidance and our ‘Overview to GDPR’ and that you are drawing on our wider resources.

One consistent feature of our outreach with organisations is a high demand for granular guidance – often people will say to us: “tell us what we need to do”.

We are working at pace to produce detailed guidance, both at national level but also European level guidance produced by the Article 29 EU Working Party to which we are making a major contribution.

I will flag up some particular pieces of guidance in a minute, and the pipeline of guidance will continue to flow.

But I urge you not to wait, nor to take a reactive approach to your GDPR preparations, motivated solely by a mindset of compliance or risk management.

Those organisations which thrive under GDPR will be those who recognise that the key feature of GDPR is to put the individual at the heart of data protection law.

Thinking first about how people want their data handled and then using those principles to underpin how you go about preparing for GDPR means you won’t go far wrong.

Transparency and accountability

It can be boiled down to two words: “transparency” and “accountability”.

Being clear with individuals how their personal data is being used.

And placing the highest standards of data protection at the heart of how you do business.

An issue for the boardroom

That means this is an issue for board level, whatever the size of your business.

Not least because under GDPR the regulator wields a bigger stick. For the most serious violations of the law, the ICO will have the power to fine companies up to twenty million Euros or four per cent of a company’s total annual worldwide turnover for the preceding year.

And as we’ve seen in well-publicised examples the cost to business of poor practice in this area goes above and beyond any fine we can impose. Losing your consumers’ trust could be terminal for your reputation and for your organisation.

We would all prefer a win-win outcome. A model where organisations take an approach to data protection which earns the trust of consumers in a more systematic way. And where that trust translates into competitive advantage for those who lead the charge.

Nowhere does that feel more relevant than for your sector.

GDPR and the tech sector

The UK tech industry is at the forefront of our vibrant digital economy, changing how we live our lives and offering huge potential for positive change and wide social benefit.

Data is the fuel that powers that economy and tech companies are involved at every level.

GDPR is a response to this evolving landscape, building on previous legislation but bringing a 21stcentury approach and delivering stronger rights in response to the heightened risks.

The right of an individual to be informed about use of their data; their right to access their information and move that information around; the right of rectification and erasure of data where appropriate; the right to remove consent; and the right to enable automated decisions to be challenged.

Good practice tools that the ICO has championed for a long time – such as privacy impact assessments and ensuring privacy by design – are now legally required in certain circumstances.

The ICO covers privacy impact assessments in its existing Privacy by Design guidance and the European Article 29 Working Party has also issued draft guidelines.

Being transparent and providing accessible information to individuals about how you will use their personal data is another key element of the new law and our privacy notices code of practice is GDPR-ready.

Increased responsibilities for data processors are another feature. Data processors, companies using personal data on behalf of others, will have specific legal obligations to maintain records of personal data and processing activities.

Data breach reporting will also change under the GDPR. You’ll be obliged to notify the ICO, within 72 hours, of a breach where it is likely to result in a risk to the rights and freedoms of individuals.

The widespread availability of personal data on the internet and advances in technology, coupled with the capabilities of big data analytics mean that profiling is becoming a much wider issue.

People have legitimate concerns about surveillance, discrimination and the use of their data without consent.

Data protection can be challenging in a big data context and some types of big data analytics, such as profiling, can be intrusive.

We explore many of these issues in detail in our recently updated paper on big data, artificial intelligence, machine learning and data protection.

We’ve also recently published a consultation paper on profiling under GDPR to which TechUK has responded. We’ll be using this to feed into the European Article 29 Working Party guidelines.

Harnessing the benefits of big data, AI and machine learning, as it relates to healthcare for example, will be sustained by upholding the key data protection principles and safeguards set out in GDPR.

Whilst the means by which personal data is processed are changing, the underlying issues remain the same. Are people being treated fairly? Are decisions accurate and free from bias? Is there a legal basis for the processing? These will remain key questions for us as a regulator under GDPR as they have been under the DPA.

The GDPR is a principles based law well equipped to take on the challenges of 21stcentury technology.

It aims to be flexible – protecting individuals from harm while enabling you to innovate and develop services that consumers and businesses want.

Data analytics

As data becomes the fuel powering the modern economy, so it becomes a key element of many of the debates in modern society.

Take the announcement last week by Elizabeth Denham of her opening of a formal investigation into the use of data analytics for political purposes.

Given the big data revolution I have mentioned it is understandable that political campaigns are exploring the potential of advanced data analysis tools to help win votes. The public have the right to expect that this takes place in accordance with the law as it relates to data protection and electronic marketing.

This is a complex and rapidly evolving area of activity and the level of awareness among the public about how data analytics works, and how their personal data is collected, shared and used through such tools, is low.

What is clear is that these tools have a significant potential impact on individuals’ privacy. It is important that there is greater and genuine transparency about the use of such techniques to ensure that people have control over their own data and the law is upheld.

We will provide an update on that investigation later in the year.

Rising to the challenge

I’ve talked about some of the challenges and opportunities GDPR brings for organisations. Likewise it is a moment for us at the ICO to reflect on how we do our work.

Clearly there are practical aspects such as preparing for a higher volume of activity given enhanced breach notification requirements.

But we are thinking more widely than that.

One example, again with particular relevance for the tech sector, is how we might be able to engage more deeply with companies as they seek to implement privacy by design.

How we can contribute to a “safe space” where companies can test their ideas. How we can better recognise the circular rather than linear nature of the design process.

Separate but related we need to become more comfortable about recognising good practice and drawing on exemplars.

We should be able to find ways to give credit where credit is due without that translating into a free pass for an individual organisation or practice. GDPR explicitly foresees wider use of tools such as codes of conduct and certification schemes, which potentially have an important role to play.

To deliver on the above and more broadly we also need to build our own tech know-how and capability. We are working on a new Technology Strategy which will outline our means of adapting to rapid technological change as it impacts information rights.

We are also committed to exploring innovative and technologically agile ways of protecting privacy.

And of course we need to exercise global reach and influence. Effective protection of the UK public’s personal information becomes increasingly complex as data flows across borders.

The ICO will continue to develop and deepen effective relationships with our international partners, reacting to changes in the global regulatory environment.

These goals among others feature in our new Information Rights Strategic Plan, being launched today by Elizabeth Denham, which sets out the ICO’s plan for the coming four years.

The tech sector will be a priority for our engagement as we look to seize these opportunities set out in the strategy.

Conclusion

With 12 months to go until GDPR takes effect in the UK, I hope I have offered a brief insight into some of the implications and impacts of GDPR on UK businesses.

I hope I have also signposted key actions you should be taking and key tools on which you can draw to rise to the challenge.

GDPR brings big changes, important changes. But GDPR is an evolution of the existing rules, not a revolution.

And as I said at the outset it is also a mirror of the changes in the practices and environment it seeks to regulate.

It is not GDPR which is pushing data protection up the public, political and media agenda. It is the changing nature of the world in which we live, and the ubiquity of data, which is causing society to reflect on the consequences for our personal information and for privacy itself.

You are at the heart of that change. Your response to the challenges and opportunities of GDPR will set a marker for other sectors.

You have a major stake in the enterprise of increasing data trust and confidence among the UK public. By putting the individual in genuine control of their own data you can help achieve that goal, delivering benefits for your consumers, your business and society as a whole.

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6th march Manchester, UK.

Good morning, and welcome to Manchester. It’s cold and it’s grey, but for those of us who live around here, we kind of like it, and we’re proud it’s where the biggest data protection conference of the year takes place.

We’ve got a busy schedule today. Lots on GDPR, of course. Trevor Hughes from IAPP talking about the role of the data protection officer internationally. Practical workshops on everything from breach notification to consent. And a very engaging information market – the speakers’ corner looks sure to be a conversation starter, and don’t miss our experts talking about the law enforcement directive too.

So lots to engage you. Let’s get started by getting your grey matter warmed up: a quick general knowledge quiz. One question:

What links the following:

the Labour Party;

international weightlifting;

the music you heard when I entered the room; and

the ICO?

The answer is right before your eyes: all have performed right here at this venue. I’m not sure which of the four had the rowdiest audience…!

Manchester Central has been the home of the Data Protection Practitioners Conference for the best part of a decade, and I’m sure you’ll agree it’s an excellent venue. It was converted from a railway station built more than 125 years ago by Sir John Fowler, the architect famed for his work on the Forth Railway Bridge.

Sir John once said: “Engineers are not mere technicians and should not approve or lend their name to any project that does not promise to be beneficent to man and the advancement of civilization.”

DPOs in the mainstream

I think there’s something in that comment for us here today. About not merely being technicians. About looking to see how the projects we contribute to can be beneficial to citizens. How we can put the customer first.

I don’t think that’s too grand an aim. This is an exciting time to be in data protection. Like many of you, I’ve worked in this sector a long time. I remember when we were a back office function. When we often were seen as “mere technicians”. That seems a very long time ago.

My colleague Rob Luke, who you’ll hear from shortly, is speaking before an advertising conference later this week. Fifteen years ago, which advertiser would have invited the data protection regulator to their annual event? Who thought data protection when they booked a slot in the ad break during Coronation Street? But today, data protection is central to their work. Making the most of customer data. Combining big data sets. Finding new ways to better understand what consumers want, to track how they act or predict what they will do next.

Last week, we opened an inquiry into privacy risks arising from the use of data analytics for political purposes following public reports about the role of private firms in the Brexit referendum. We often find ourselves at the heart of many debates of modern society.

It’s an exciting time to work in data protection, whatever your sector, with real opportunities. We’ll talk a lot today about the practical aspects, from how GDPR will change things at your organisations, to the steps you can take to use the coming change in the law as an opportunity to inform your practices.

But let’s not lose sight of what good data protection can achieve. We have an opportunity to set out a culture of data confidence in the UK. We just need to keep in mind that when we lend our name to projects, we should think about how they can be of benefit to citizens.

Review of last 12 months

I think it’s fair to say that a recap of the files we’ve been involved in over the past twelve months can be characterised by organisations failing to put customers first.

Our work with WhatsApp and Facebook springs to mind. We all rely on digital services for important parts of our lives. But my office felt these apps were not taking enough responsibility for data protection. Companies have legal responsibilities to treat people’s data with proper care and transparency – to give them persistent control and choice.

Similarly the record fine we issued to TalkTalk. You could write an essay discussing the technical detail of the cyber-attack itself, but fundamentally, not enough respect – not enough care – was being given to the type of protection consumers would have expected of their personal information.

And without rehearsing the conversations we’ve had with parts of charity sector, there’s a similar theme: insufficient thought about the level of transparency donors would want, expect, or support.

They’re examples of organisations getting it wrong under the current Data Protection Act. GDPR is going to put even more of an onus on organisations to understand and respect the personal privacy rights of consumers.

GDPR

Because while the General Data Protection Regulation builds on the previous legislation, it provides more protections for consumers, and more privacy considerations for organisations. It brings a more 21st century approach to the processing of personal data.

The GDPR gives specific new obligations for organisations, for example around reporting data breaches and transferring data across borders.

But the real change for organisations is understanding the new rights for consumers.

Consumers and citizens will have stronger rights to be informed about how organisations use their personal data. They’ll have the right to request that personal data be deleted or removed if there’s no compelling reason for an organisation to carry on processing it, and new rights around data portability and how they give consent.

On that subject, do take a look at the guidance on consent that is now out for consultation, and will be discussed at our workshop later today.

Accountability and breadth

At the centre of the GDPR is the concept of broader and deeper accountability for an organisation’s handling of personal data. The GDPR brings into UK law a trend that we’ve seen in other parts of the world – a demand that organisations understand, and mitigate – the risks that they create for others in exchange for using a person’s data. It’s about a framework that should be used to build a culture of privacy that pervades an entire organisation. It goes back to that idea of doing more than being a technician, and seeing the broader responsibility and impact of your work in your organisation on society.

Making it matter to the boardroom

I’ve already spoken to some of you this morning, and I hear what you’re saying. You understand why having your organisation accept more accountability for data protection matters. You want to change the culture of your organisation. But in many cases, you need to convince your senior management first. So, what can I give you today to help you make that case when you go back to your offices tomorrow?

The fines are the obvious headline. The GDPR gives regulators greater enforcement powers. If an organisation can’t demonstrate that good data protection is a cornerstone of their business policy and practices, they’re leaving themselves open to enforcement action that can damage their public reputation and possibly their bank balance. That makes data protection a boardroom issue.

But there’s a carrot here as well as a stick, and as regulators we actually prefer the carrot. Get data protection right, and you can see a real business benefit.

Accepting broad accountability for data protection encourages an upfront investment in privacy fundamentals, but it offers a payoff down the line, not just in better legal compliance, but a competitive edge. Whether that means attracting more customers or more efficiently meeting pressing public policy needs, I believe there is a real opportunity for organisations to present themselves on the basis of how they respect the privacy of individuals. Over time this can play a real role in consumer choice.

What the ICO is doing

Gandhi said the future depends on what we do in the present. So let me talk a little about what my office is doing now, to help you prepare for the future.

I’ve worked as a regulator in this field for more than twelve years and my focus has always been on making sure the regulator is relevant. On making sure we’re taking on that challenge of not being mere technicians but instead are making a difference to the organisations we regulate through education. Making a difference to the public, through giving them an avenue to file a complaint and by sanctioning the bad actors.

Each of us in the information rights field, on a daily basis, tries to make a difference to the public. Collectively, we do a good job: I think people have never been more aware of their rights, of what they can expect of the businesses and organisations they trust with their data. But consumer trust hasn’t followed that. An ICO survey last year showed only one in four UK adults trust businesses with their personal data. And I don’t believe the figure would be much higher for the public sector. As a regulator, it’s one of my jobs to give you the tools and the support to turn that around.

I want to see comprehensive data protection programs as the norm, organisations better protecting the data of citizens and consumers, and a change of culture that makes broader and deeper data protection accountability a focus for organisations across the UK. I think that’s achievable.

We’ll be shortly announcing work we’ll be doing to contribute to that. We want to support independent research that helps people better navigate the digital world. Our research and grants programme will dedicate funds over the next five years to engaging the research community in finding ways to help consumers. More details in due course.

Post Brexit

And of course we need to be looking to the horizon, to what might exist beyond GDPR.

Fourteen months ago I was writing a speech for a different audience, in a different role. My appearance was at the Canadian annual privacy and security conference, as information and privacy commissioner for British Columbia. I was talking about the challenges of a digital economy that required data to flow across borders, where different legal systems and cultural norms about privacy make this a complicated undertaking. More specifically, I spoke about how changes within the EU affect those outside of it, particularly around adequacy.

How familiar does that sound today? The UK EU referendum decision means we’re facing the same challenges. The UK’s digital economy needs data to flow across borders: how do we make sure that can happen? How can we foster economic growth while still respecting citizen’s rights?

When the government comes to answer those questions beyond the implementation of GDPR in 2018, we expect to be at the centre of many conversations, speaking up for continued protection and rights for consumers, and clear laws for organisations. And addressing the strong data protection laws we’d need if we want to keep the UK’s approach at an equivalent standard to the EU.

Conclusion

Which brings us back to today. The GDPR is a strong data protection law. It gives consumers more control over their data. And it includes new obligations for organisations.

Today is about learning more about those obligations, more about data protection best practice, more about how to get it right.

European politicians met on the 24th June 2015 in a bid to ratify huge changes in data protection regulation, but a survey has revealed UK businesses are woefully unprepared.

The EU General Data Protection Regulation aims to unify data protection across Europe with a single law and will be fine-tuned in Brussels at a ‘trilogue’ meeting of the EU Commission, European Parliament and the Council of the EU.

Once passed, it will bring with it huge fines (up to 100m Euros or 2% of global turnover) for companies that breach the regulation – as well as a raft of new rules about collecting, editing and processing the personal data of European citizens. Many companies will also be compelled to employ at Data Protection Officer for the first time.

Experts predict it will affect every single company that operates from within the EU, does business with companies inside the EU, stores its data in EU member countries or handles the personal data of European citizens.

A Crown Records Management Censuswide survey of IT decision makers at UK companies with more than 200 employees revealed businesses here are painfully unprepared – and one in five hasn’t even heard of the Regulation.

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Skyhigh Networks released its new “Cloud Adoption & Risk in the Government Report.” The Q1 2015 report reveals that shadow IT is prevalent in government agencies.

The average public sector organization uses 742 cloud services, which is about 10-20 times more than IT departments expect. Despite the security initiatives in place, such as FedRAMP, FISMA, and FITARA, many government employees are unaware of agency rules and regulations or simply ignore them and use cloud services that drive collaboration and productivity.

As agencies grapple with how to manage shadow IT and securely enable sanctioned IT, they need visibility into the real usage and risk of cloud services as well as the ability to detect threats and seamlessly enforce security, compliance, and governance policies,” said Rajiv Gupta, CEO of Skyhigh Networks. “Skyhigh manages shadow IT and securely enables sanctioned IT, allowing public sector organizations to use hundreds of cloud services while providing robust data protection services, thereby meeting data privacy requirements and conforming to regulations

Despite clear benefits of cloud services Federal agencies are slow to migrate to the cloud due to security concerns. As a result, employees adopt cloud services on their own, creating shadow IT. Under FITARA, Federal CIOs must oversee sanctioned cloud services as well as shadow IT. This new requirement underscores the uncertainty about how employees are using cloud services within their agencies.

Understanding Shadow IT
The average public sector organization now uses 742 cloud services, which is about 10-20 times more than IT departments report. What agencies don’t know can hurt them. When asked about insider threats, just 7% of IT and IT security professionals at public sector organizations indicated their agency had experienced an insider threat. However, looking at actual anomaly data, Skyhigh Networks found that 82% of public sector organizations had behavior indicative of an insider threat.

Agencies cannot rely on the security controls offered by cloud providers alone. Analyzing more than 12,000 cloud services across more than 50 attributes of enterprise readiness developed with the Cloud Security Alliance, the report found that just 9.3% achieved the highest CloudTrust Rating of Enterprise Ready. Only 10% of cloud services encrypt data stored at rest, 15% support multi-factor authentication, and 6% have ISO 27001 certification. Skyhigh Networks helps Federal agencies address these security gaps and gain control over shadow IT by providing unparalleled visibility, comprehensive risk assessment, advanced usage and threat analytics, and seamless policy enforcement.

Password Insecurity
Compromised credentials can also mean disaster for Federal agencies. According to a study by Joseph Bonneau at the University of Cambridge, 31% of passwords are used in multiple places. This means that for 31% of compromised credentials, attackers can potentially gain access not only to all the data in that cloud service, but all the data in other cloud services as well. The average public sector employee uses more than 16 cloud services, and 37% of users upload sensitive data to cloud file sharing services. As a result, the impact of one compromised account can be immense.

The Skyhigh “Cloud Adoption & Risk in the Government Report” reveals that 96.2% of public sector organizations have users with compromised credentials and, at the average agency, 6.4% of employees have at least one compromised credential.

Cloud Services in the Public Sector
Most cloud services deployed in the public sector are collaboration tools. The average organization uses 120 distinct collaboration services, such as Microsoft Office 365, Gmail, and Cisco Webex. Other top cloud services are software development services, file sharing services, and content sharing services. The average employee uses 16.8 cloud services including 2.9 content sharing services, 2.8 collaboration service, 2.6 social media services, and 1.3 file sharing services. Shockingly, the average public sector employee’s online movements are monitored by 2.7 advertising and web analytics tracking services, the same services used by cyber criminals to inform watering hole attacks.

The report also reveals the top cloud services used in the public sector.

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Corporate Data: A Protected Asset or a Ticking Time Bomb? is a Ponemon Institute study sponsored by Varonis, surveying a total of 2,276 employees in US and European organizations (United Kingdom, Germany and France), including 1,110 individuals (hereafter referred to as end users) who work in such areas as sales, finance and accounting, corporate IT, and business operations, and 1,166 individuals who work in IT and IT security (hereafter referred to as IT practitioners).

In the context of this research, both IT practitioners and end users are witnessing a lack of control over their organizations’ data and access to it, and the two groups generally concur that their organizations would overlook security risks before they would sacrifice productivity. Employees are often left with needlessly excessive data access privileges and loose data-sharing policies.

Compounding the risk, organizations are unable to determine what happened to data when it goes missing, indicating a lack of monitoring and further absence of controls.

This presents a growing risk for organizations due to both accidental and conscious exposure of sensitive or critical data. Efforts to address these risks will need to overcome employee perceptions, as they believe data protection is not considered a high priority by senior leadership.

Following are research findings that illustrate the growing risks and challenges to productivity that data growth and a lack of internal controls currently present for organizations of all sizes:

End users believe they have access to sensitive data they should not be able to see, and more than half say that access is frequent or very frequent. 71% of end users say that they have access to company data they should not be able to see. 54% characterize that access as frequent or very frequent.

End users believe data protection oversight and controls are weak. 47% of end users say the organization does not strictly enforce its policies against the misuse or unauthorized access to company data and 45% say they are more careful with company data than their supervisors or managers. Furthermore, only 22% of employees say their organization is able to tell them what happened to lost data, files or emails.

IT agrees. Most IT practitioners surveyed state that their companies do not enforce a strict least-privilege (or need-to-know) data policy. Four in five IT practitioners (80%) say their organizations don’t enforce a strict least-privilege data model. 34% say they don’t enforce any least-privilege data model.

End users and IT agree that data growth is hindering productivity more every day. 73% of end users believe the growth of emails, presentations, multimedia files and other types of company data has very significantly or significantly affected their ability to find and access data.

Uncertainty about whether senior executives view data protection as a priority affects. compliance with security policies. Only 22% of end users believe their organizations overall place a very high priority on data protection. About half (51%) of IT practitioners believe their CEO and other C-level executives consider data protection a high priority.

IT practitioners say end users are likely to put critical data at risk. 73% of IT practitioners say their department takes data protection very seriously. However, only 47% believe employees in their company take the necessary steps to make sure confidential data is secure. Thus, IT departments know end user security risks exist but think they are limited in what they can do about it.

End users think it is OK to transfer confidential documents to potentially unsecure devices. 66% of end users say there are times when it is acceptable to transfer work documents to their personal computer, table, smart phone and even the public cloud. Only 13% of IT practitioners agree.

End users and IT practitioners do not think their organization would accept diminished productivity to prevent the risk to critical data. 55% of end users say their company’s efforts to tighten security have a major impact on their productivity. Only 27% of IT practitioners say their organization would accept diminished productivity to prevent the loss or theft of critical data.

End users and IT agree that employees are unknowingly the most likely to be responsible for the leakage of company data. 64% of end users and 59% of IT practitioners believe that insiders are unknowingly the most likely to be the cause of leakage of company data. And only 46% of IT practitioners say employees in their organizations take appropriate steps to protect the company data they access.

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Advisen Ltd and Zurich have partnered for a fourth consecutive year on a survey designed to gain insight into the current state and on going trends in information security and cyber liability risk management. Invitations to participate were distributed via email to risk managers, insurance buyers and other risk professionals. The survey was completed at least in part by 507 respondents.

The majority of respondents classified themselves as either

Member of Risk Management Department (not head) (38%)

Chief Risk Manager/Head of Risk Management Department (33%)

Respondents with more than 20 years of risk management and insurance experience represented the largest group at 39% of the total, followed by 25% with between 11 – 20 years, 18% with 5 years or less, and 17% with between 6 – 10 years.

A summary of the survey is below.

Perception of Cyber Risks

Respondents’ perception of cyber risk is largely unchanged from last year with 88% considering cyber and information security risks to be at least a moderate threat to their organization. Respondents do however believe that board members and executive management are viewing cyber risks more seriously.

Perception of risk varies based on size of business. Although studies have suggested that small companies are targeted as frequently, if not more so, than larger companies, as a group they continue to view cyber risks less seriously. In response to the question

“How would you rate the potential dangers posed to your organization by cyber and information security risks?”

81% of the smallest companies (revenues less than $250 million) consider cyber risks to be at least a moderate danger

93% of the largest companies (revenue greater than $10 billion) consider them to be so.

Consistent with last year’s study, on a scale of one to five, with 5 as very high risk and 1 as very low risk, “damage to your organization’s reputation resulting from a data breach” is the biggest concern of respondents with 64% rating it a 4 or 5. This was closely followed by “incurring costs and expenses from a cyberattack” with 62%, and “privacy violation/data breach of customer records” with 61%.

In contrast, the exposure perceived as the least risky was “theft or loss of customer intellectual property” with 43% rating it a 1 or 2. This was followed by “business interruption due to customer cyber disruptions” with 33%, and “employment practice risk due to use of social media” with 32%.

Data Breach Response

Over the past year, huge and highly recognizable U.S. businesses have fallen victim to some of the largest data breaches in history. These breaches are proof that even those with the most sophisticated information security practices and infrastructures are vulnerable to a cyber-attack. Some suggest that corporate data breaches are no longer an “if” or even a “when” proposition, but rather “how bad” will the inevitable breach be. When a breach does occur, research suggests that organizations that have data breach response plans in place prior to a breach, fare much better than those who do not.

“Does your organization have a data breach response plan in the event of a data breach?”

62% said yes

14% said no

24% did not know

“In the event of a data breach, which department in your organization is PRIMARILY responsible for assuring compliance with all applicable federal, state, or local privacy laws including state breach notification laws?”

IT – 38%

General Counsel – 21% received the highest percentage of the responses.

Information Security and Cyber Risk Management Focus

Consistent with the 2013 survey, 80% claim that information security risks are a specific risk management focus within their organization. Larger companies are slightly more likely to make it a focus with 83% of companies with revenues in excess of $1billion doing so, compared with 77% with revenues under $1billion. However, the 6% point difference between small and large companies is significantly less the 17% difference from a year ago.

The difference is even more significant when comparing the largest companies (revenues of $10 billion or greater) and the smallest companies (revenues of $250 million or less), with 92 % of the largest companies making information security a risk management focus compared with only 72% of the smallest companies.

For a second consecutive year, the percentage of respondents with a multi-departmental information security risk management team or committee has declined, 52% have an information security risk management team or committee which is down from 56% in 2013, and 61% in 2012. Although statistically still within the margin of error, this is a potential trend worth following. As in previous years, however, this varies materially based on the size of company with 58% of larger companies ($1billion in revenue or greater) claiming to have this team or committee compared to 42% of smaller companies (under $1billion in revenue).

The departments most likely to have representation on the information security risk management team are:

IT – 90%

Risk Management/Insurance – 73%

General Counsel – 63%

Compliance – 55%

Internal Audit – 47%

Treasury or CFO’s Office – 40%

Chief Privacy Officer – 36%

Marketing – 10%

Investor Relations – 6%

Sales – 5%

9% Didn’t Know

15% said Other

The most common write-in responses under “Other” were Operations and Security

The IT department is still acknowledged as the front line defense against information losses and other cyber liability risks. In response to the question “Which department is PRIMARILY responsible for spearheading the information security risk management effort?”

69% responded IT

11% Risk Management/Insurance

5% responded Other. The most common other being Information Security

Social Media

Social media provides businesses with an array of benefits such as increasing brand awareness, promoting products, and providing timely support. It also exposes organizations to a degree of risk, such as the potential for reputational damage, privacy issues, infringing other intellectual property, and data breaches.

“Does your organization have a written social media policy?”

74% responded yes

17% no

Cloud Services

For a third consecutive year respondents were asked questions on cloud services. Thanks to its cost effectiveness and increased storage capacity, cloud services have become a popular alternative to storing data in-house. Warehousing proprietary business information on a third-party server, however, makes some organizations uncomfortable due to the lack of control in securing the information. Nonetheless, security concerns continue to be outweighed by the benefits.

“Does your company use cloud services?”

66% responded yes, up from 55% last year, and 45% in 2012.

“Is the assessment of vulnerabilities from cloud services part of your data security risk management program?”

51% responded yes – consistent with last year

Mobile Devices

“Does your organization have a mobile device security policy?”

74 % said yes

15 % said no

13 % did not know

Larger companies continue to be more likely to have such a policy with

82 % of large companies ($1 billion or greater) responding yes

62 % of smaller companies ($1 billion or less).

The use of personal handheld devices for business purposes is increasingly preferred by employees and allowed by employers. These non-company controlled devices, however, are accessing proprietary corporate information and frequently exposing organizations to a higher degree of risk.

“Does your organization have a bring your own device (BYOD) policy?”

47% responded yes which is consistent with last year’s response.

The Role of Insurance in Information Security and Cyber Risk Management

The upward trend in the percentage of companies purchasing cyber liability insurance plateaued in 2014.

“Does your organization purchase cyber liability insurance?”

52% responded yes

35% said no

13% did not know

Of the respondents who purchase coverage

32% have purchased it for less than two years

47% between three and five years

22% for more than five years

The percentage of companies who buy coverage for loss of income due to a data breach dropped slightly from 54 % in 2013 to 48 % this year.

Finally, respondents that do not currently purchase cyber insurance were asked “Are you considering buying this coverage in the next year?” 54% said yes. This was only a one percentage point increase from 2013.

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Ponemon Institute has released its CA Technologies sponsored study “The Identity Imperative for the Open Enterprise: What IT Users and Business Users Think about Bring Your Own Identity (BYOID).

They surveyed 1,589 IT and IT security practitioners and 1,526 business users with more than 1,000 employees in United States, Australia, Brazil, Canada, France, Germany, India, Italy and the United Kingdom to understand current trends in Bring your Own Identity or BYOID, which is defined as the use of trusted digital or social networking identities.

74% of the IT users surveyed report to the CIO

15% report to the CISO

55% of the business users in this research report to the lines of business leader

10% report to the marketing officer

The majority of respondents in both groups have high levels of interest in BYOID, but IT users and business user groups have different views about the perceived potential value of BYOID.

Business end users are more interested in how BYOID can streamline customer’s experience and assist in targeted marketing campaigns.

Some of these differences can be expected because of the different job responsibilities of each group. These differences do not necessarily portend conflict, but rather show the need for collaboration between IT and the business functions to yield maximum benefits for any organisation deploying a BYOID system. By developing a cross-functional BYOID strategy around several well-defined use cases, organisations can differentiate themselves from competitors and further grow their business.

Key finding of the study are:

The Application Economy Drives BYOID Interest

In today’s application economy, organisations need to securely deliver new apps to grow their business quickly. This can increase IT risks, which puts a premium on an organisation’s ability to simplify the user experience without sacrificing security. Using an existing digital or social identity issued by a trusted third party to access applications can help organisations meet the need for simplicity, security and a positive customer experience.

67% of IT users say the primary value of BYOID is from strengthening the authentication process

54% from reducing impersonation risk

79% of Business users believe the BYOID value comes from delivering a better customer experience 76% believe it is from increasing the effectiveness of marketing campaigns

While IT sees value primarily in risk mitigation/cost reduction, business users see the value of BYOID in improving the consumer experience to increase customer loyalty and generating new revenue streams. This underscores the need for IT and business collaboration to address the challenge that today’s organisations face: how to secure the business while simultaneously empowering

Mobile and Web Users Drive BYOID

Today’s IT organisations must deliver secure access to a highly distributed and growing user population. These users expect to access information anywhere, anytime from multiple devices. This is changing how user identities should be managed and is affecting the demand for BYOID.

When IT practitioners and business users were polled on their level of interest in accepting identities for different user populations such as job prospects, employees, contractors, retirees, website customers or mobile customers, mobile and web customers received the most interest, far exceeding that of the other populations.

50% of IT respondents and 79% of business respondents have very high or high interest in BYOID for website user populations

48% of IT respondents and 82% of business respondents have very high or high interest in BYOID for mobile user populations

BYOID Requires Security Enhancements to Drive More Adoption

While the survey results indicate interest in BYOID from both IT users and business users, both groups identified features that could contribute to broader BYOID adoption.

When asked which features would most likely increase BYOID adoption within their organisation;

73% of IT users’ top features are identity validation processes

66% have multi-factor authentication as the top feature

71% of Business users say both identity validation processes and simplified user registration are the most popular features for increasing adoption.

The study also indicates a high level of interest for some level of accreditation of the identity providers

59% of IT saying it is essential or very important

21% saying it is important

27% of business respondents say accreditation is essential or very important with 48% believe it’s important

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The Information Commissioner’s Office (ICO) is warning barristers and solicitors to keep personal information secure, especially paper files. This follows a number of data breaches reported to the ICO involving the legal profession.

The ICO can serve a monetary penalty of up to £500,000 for a serious breach of the Data Protection Act provided the incident had the potential to cause substantial damage or substantial distress to affected individuals.

In most cases these penalties are issued to companies or public authorities, but barristers and solicitors are generally classed as data controllers in their own right and are therefore legally responsible for the personal information they process.

In the last three months, 15 incidents involving members of the legal profession have been reported to the ICO. The information handled by barristers and solicitors is often very sensitive. This means that the damage caused by a data breach could meet the statutory threshold for issuing a financial penalty. Legal professionals will also often carry around large quantities of information in folders or files when taking them to or from court, and may store them at home. This can increase the risk of a data breach.

Information Commissioner, Christopher Graham, said:

The number of breaches reported by barristers and solicitors may not seem that high, but given the sensitive information they handle, and the fact that it is often held in paper files rather than secured by any sort of encryption, that number is troubling. It is important that we sound the alarm at an early stage to make sure this problem is addressed before a barrister or solicitor is left counting the financial and reputational damage of a serious data breach.

“We have published some top tips to help barristers and solicitors look after the personal information they handle. These measures will set them on the road to compliance and help them get the basics right

The ICO has published the following top tips to help barristers and solicitors keep the personal information they handle secure

Keep paper records secure. Do not leave files in your car overnight and do lock information away when it is not in use.

Consider data minimisation techniques in order to ensure that you are only carrying information that is essential to the task in hand.

Where possible, store personal information on an encrypted memory stick or portable device. If the information is properly encrypted it will be virtually impossible to access it, even if the device is lost or stolen.

When sending personal information by email consider whether the information needs to be encrypted or password protected. Avoid the pitfalls of auto-complete by double checking to make sure the email address you are sending the information to is correct.

Only keep information for as long as is necessary. You must delete or dispose of information securely if you no longer need it.

If you are disposing of an old computer, or other device, make sure all of the information held on the device is permanently deleted before disposal.

The ICO is currently working with The Bar Council to update the Information Security Guidance provided to Barristers in England and Wales.

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According to IDG research in a CSG Invotas white paper “Security Automation: Time to Take a Fresh Look” most organisations struggle to resolve the effects of a breach.

There’s no doubt that improving intrusion response and resolution times reduces the window of exposure from a breach,” said Jen McKean, research director at IDG Research. “More companies seek security automation tools that will enable them to resolve breaches in mere seconds and help maintain business-as-usual during the remediation period

Researchers polled decision makers of information security, strategy, and solution implementations at companies with 500 or more employees. They explored the security challenges commercial organizations face when confronted with security breaches across their networks. Key findings include:

46% of respondents report an average detection time of hours or days

54% reporting average resolution times of days or months

On going management of electronic identities that control access to enterprise, cloud, and mobile resources take the most time to change or update during a security event

A majority of respondents seek ways to reduce response time in order to address risk mitigation, preserve their company’s reputation, and protect customer data

61% of respondents admit they are looking for ways to improve response times to security events

82% of respondents report no decrease in the number of network security events or breaches last year whilst more than a quarter of those surveyed report an increase

60% of IT Security Resources dedicated to protecting the network layer

10% of respondents reporting they’re able to resolve issues in seconds or minutes; 54% say it takes days, weeks or months

28% of respondents say the number of security events or breaches increased in 2013

24% report that the severity of incidents increased

39% of respondents say they can detect a security breach within seconds or minute

Business process automation solutions offer a new approach to the most difficult step in security operations: taking immediate and coordinated action to stop security attacks from proliferating. Building digital workflows that can be synchronized across an enterprise allows a rapid counter-response to cyber-attacks. Speed, accuracy, and efficiency are accomplished by applying carrier-grade technology, replicating repetitive actions with automated workflows, and reducing the need for multiple screens.

It is no longer a surprise to hear that a breach has compromised data related to customers, employees, or partners,” said Paul Nguyen, president of global security solutions at CSG Invotas. “CIOs recognize that they need faster, smarter ways to identify security breaches across their enterprises. More importantly, they need faster, smarter ways to respond with decisive and coordinated action to help protect threats against company reputation, customer confidence, and revenue growth

A quarter of respondents say they are comfortable with the idea of automating some security workflows and processes and that they deploy automation tools where they can. 57% of respondents say they are somewhat comfortable with automation for some low-level and a few high-level processes, but they still want security teams involved. On average, respondents report that 30% of their security workflows are automated today; but nearly two-thirds of respondents expect they will automate more security workflows in the coming year.

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Information security breaches affecting UK business have decreased over the last year but the cost of individual breaches has almost doubled.

The number of information security breaches affecting UK businesses has decreased over the last year but the scale and cost of individual breaches has almost doubled.

The Information Security Breaches Survey 2014, commissioned by the Department for Business, Innovation and Skills (BIS) and carried out by PwC, found

81% of large organisations suffered a security breach, down from 86% a year ago

60% of small businesses reported a breach, down from 64% in 2013

Although organisations are experiencing fewer breaches overall, the severity and impact of attacks has increased, with the average cost of an organisations’ worst breach rising significantly for the third consecutive year. For small organisations the worst breaches cost between £65,000 and £115,000 on average and for large organisations between £600,000 and £1.15 million.

The majority of businesses have increased IT security investment over the last year

Universities and Science Minister David Willetts said:

These results show that British companies are still under cyber attack. Increasingly those that can manage cyber security risks have a clear competitive advantage. Through the National Cyber Security Programme, the government is working with partners in business, academia and the education and skills sectors to equip the UK with the professional and technical skills we need for long-term economic growth.”

Andrew Miller, cyber security director at PwC, said:

Whilst the number of breaches affecting UK business has fallen slightly over the past year the number remains high and in many companies more needs to be done to drive true management of security risks. Breaches are becoming more sophisticated and their impact more damaging. Given the dynamic nature of the risk, boards need to be reviewing threats and vulnerabilities on a regular basis. As the average cost of an organisation’s worst breach has increased this year, businesses must make sure that the way they are spending their money in the control of cyber threats is effective. Organisations also need to develop the skills and capability to understand how the risk could impact their organisation and what strategic response is required.”

70% of companies that have a poor understanding of security policy experienced staff related breaches, compared to only 41% in companies where security is well understood. This suggests that communicating the security risks to staff and investing in on going awareness training results in fewer breaches.

The survey also found that there has been an increase in the number of businesses which are confident that they have the skills required within their organisations to detect, prevent and manage information security breaches, up to 59% from 53% last year.

Ensuring that we have the cyber skills capability to meet the evolving needs of businesses is a key objective of the UK’s National Cyber Security Strategy. Earlier this year (2014), the government unveiled a raft of new proposals to meet the increasing demand for cyber security skills. These include a new higher-level apprenticeship, special learning materials for 11 to 14 year-olds and plans to train teachers to teach cyber security.

Earlier this year (2014) the government launched a new scheme to help businesses stay safe online. Cyber Essentials provides clarity to organisations on what good cyber security practice is and sets out the steps they need to follow, to manage cyber risks. From this summer (2014) organisations that have complied with the best practice recommendations will be able to apply to be awarded the Cyber Essentials Standard. This will demonstrate to potential customers that businesses have achieved a certain level of cyber security and take it seriously.

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SafeNet and SafeMonk have recently produced the results of a survey titled “Cloud App Usage vs. Data Privacy”.

The survey show the attitude of people, including C-Levels, to cloud storage and data privacy, a summary of the survey is below.

Do you frequently use cloud based applications (i.e. Banking, business applications, social media, etc.)?

64% Yes

25% No

11% what is a cloud based application…

Do you store any personal or professional data in the cloud?

55% Yes

28% No

14% I think so

3% not sure

Are you worried at all about the security of the cloud-based applications or data stored in the cloud?

55% Yes

32% No

15% Still trying to figure out what cloud is

Of the applications that you use, which are you most concerned about someone hacking into?

52% Banking Application

17% File Storing / Sharing Application

14% Email

9% None of the Above

8% Social Media Account

What system do you use most frequently for file storage?

39% Dropbox

25% The drawers on my desk

24% Google Drive

6% Other

5% Microsoft SharePoint

1% Box.net

Reading the above is even more interesting when you see the next question and answers.

What system for file storage and sharing does your company ask you to use?

52% Internal Network

13% Google Drive

12% Microsoft SharePoint

12% Dropbox

7% Other

3% iCloud

1% Box.net

When it comes to your data privacy, who are you most concerned with?

46% Government

22% Google

22% I’m not concerned about the privacy of my data.

6% Boss

3% Spouse

1% Mom

Does your company have a policy regarding usage of file sharing applications such as DropBox?

39% No

33% I don’t know

28% Yes

If your company has a policy against usage of applications such as DropBox, do you use it anyway?

79% Yes

21% No

What types of files do you store online?

50% Personal

24% Professional

18% Both

8% None of your business

What keeps you up at night regarding your data and personal information?

52% Nothing keeps me up at night. I sleep like a baby.

29% It will be maliciously exploited

17% The government will have visibility into my private information

2% My peers will know my secrets

What this survey suggests is that cloud app usage and document storage continue to proliferate, and that organizations should re-examine antiquated attitudes towards usage of these apps across the enterprise,” said Tsion Gonen, Chief Strategy Officer, SafeNet, Inc. “It’s clear that top-level executives understand the advantages of cloud app usage, and should enable their companies to leverage these advantages by adopting contemporary security tools and practices

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At last week’s Information Commissioners Data Protection Officers Conference in Manchester I had the privilege of being updated on the progress, or lack of progress, of the revised European Data Protection Act.

With the existing directive dating back over 17 years an upgrade is well over due but there is significant pressure from businesses to water down any revisions to the directive.

A watered down directive does not serve anyone, the privacy campaigners or those with commerce in mind, because breaches are happening far too often and breaches affect consumer confidence.

This means the larger retailers should be supporting stronger Data Protection controls so the smaller, less funded or less skilled businesses have the detailed controls and the incentives to put privacy and security first.

In the main hall and in the breakout room there was constant reference to the thinking about the issues before systems and processes are put in place. The two terms used were:-

Both Privacy by Design and Security by Design are essential for consumer confidence because they are demonstrable actions organisations can refer to when dealing with the users of their data.

Françoise Le Bail of the EU Commission stated that “23% of users feel they do not have complete control of their data when shopping online”. In other words almost a quarter of those who buy on line are suspicious of the people who want to take money from them. If those statistics were applied to bricks and mortar retailers the high street would look a lot worse than it does now and it already looks pretty bad.

Françoise Le Bail also stated that the EC’s priorities for the Act are: –

The architecture of the framework

Key provisions to include all personal data and consent

A more risk based approach – proportionality

Data Protection Offices are needed

A consistent European wide level of governance

Support for authorities by providing training and not just fines

David Smith the UK Deputy Information Commissioner stated the UK was not 100% in favour of the current draft proposals but the UK was largely supportive.

David Smith had a list of items that were favoured including:-

Improved consistency across Europe

Enhanced Individual rights

Code of conduct and certification

However, the UK is looking for additional items to be added and a clarification on others, for example:-

The UK wants a more “risk” based approach to personal data

Individual compensation should not be restricted to monetary loss. It should also take into account aggravation and heartache.

Data Protection training needs to be added to the school curriculum

There are two proposals in place by the EU and the UK doesn’t want any more than that. The two proposals are Law Enforcement and everyone else.

Other items of note

The date for the Act to be passed is likely to be June 2014 with enforcement two years later in 2016

The 24 hour mandatory breach notification is likely to slip to 72 hours

The maximum 2% of global turnover is likely to be approved but some members of the commission are pushing for it to be 10%

Right to be forgotten is a big problem due to the nature of what can be forgotten and what should never be forgotten

Data Portability is both a target for Europe and a problem and negotiations are on-going with the US and other nations on cross border data sharing.

MiData now has 26 signed up companies and the drive for more is growing